[EAS] Gorman Redlich waiver request

[Sean Donelan]

On Tue, 26 Jul 2016, Clay Freinwald wrote:
> It will be - VERY - interesting to see how the FCC Responds to this one -
> http://www.radioworld.com/article/gorman-redlich-asks-for-eas-waiver/279308

I read the Gorman Redlich waiver request on the FCC ECFS.  Gorman doesn't
identify specific legacy EAS equipment which need this EAS header rewrite. 
I assume its some of the unsupported legacy EAS boxes, since all the 
currently supported EAS boxes have updates available from their
manufacturer.

I'm not an FCC accredited testing lab, so this is NOT professional 
advice; just some personal testing.

I have some old, working Sage 1822 ENDEC boxes.  So I did some testing of 
000000 was well local FIPS location codes with the NPT and EAN event codes 
with them.  I tried all the permutations I could think of of EAN, NPT 
other event codes and FIPS codes.

Using the "All Locations" filter, the Sage 1822 will relay NPT messages
with 000000 or any other FIPS code.  It correctly translates the location 
000000 as "United States" in logs and crawls.  It may be possible to 
use a CAP-to-EAS Converter without needing Gorman Relich's waiver to 
rewrite the converted EAS header.

However....

There are several other issues beyond the 000000 location code with the 
Sage 1822. The filters can't have a specific FIPS code and 000000.  This 
means you can't relay only All U.S. and only your local FIPS area.  If 
you use a local FIPS code, you will miss the All U.S. NPT.  If you use 
"All Locations," you will relay NPT messages for All U.S. (000000), as 
well as every NPT regional message for every other FIPS code.

There are other issues such as how fast does "immediate" relay means, 
overriding hold-off tally switches, simultaneous receipt of two different 
EAS messages, prempting pending EAS messages when another EAS message 
is received, an EAN still ignores the local FIPS code and translates all
FIPS locations as United States.

Re-writing the EAS head with the state FIPS code doesn't address those 
issues.

Given all that....

A PN-only participant, e.g. LPFM station, with some limitations could
duct tape something together that would be effective, but not necessarily 
FCC accredited.

Assumptions
 	1. Can NOT use a hold-off tally switch

 	2. ONLY monitor Local Primary EAS sources and the National 
Weather Service.  It can not monitor any PEP source directly (i.e. a NPR 
squawk channel or an LP which is also a PEP).

 	3. Use a CAP-to-EAS intermediary device which ONLY relays EAS 
messages with All U.S. or local FIPS codes, but not EAS messages for other 
regions. It can't rely on the EAS device to filter out-of-region EAS 
messages. The CAP-to-EAS device should not change, add, or remove FIPS 
codes in the converted EAS header.

This will relay both EAN and NPT messages with both 000000 and local FIPS 
codes to the local EAS participant.  Its not 100% compliant, but it would 
warn the public of national emergencies.  But it could cause some 
confusion with national translations and out-of-region messages.

Are there enough legacy, unssupported EAS devices for this?  With the
cost of an FCC accredidated testing lab and communication lawyer hourly 
rates, would this actually save money?